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ALEXANDER v. GREYSTAR
2:25-cv-03300
E.D. Pa.
Jul 2, 2025
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Background

  • Liam Alexander, a Pennsylvania resident, filed a pro se complaint against his landlord, Greystar, a Pennsylvania corporation.
  • Alexander alleged that Greystar breached their contract and illegally evicted him, seeking $5 million in damages and injunctive relief.
  • He filed for leave to proceed in forma pauperis (without paying court fees).
  • The Complaint invoked federal question and diversity jurisdiction, but only referenced state-law claims (breach of contract and eviction).
  • Both parties are citizens of Pennsylvania, and no federal law basis was asserted in the Complaint.
  • The court sua sponte considered subject matter jurisdiction before addressing the merits of Alexander's claims.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Does the court have federal question jurisdiction? Alexander checked the box for federal law claims; wrote “443 Housing” Not stated (no answer yet filed) No federal law basis pled; jurisdiction lacking
Does the court have diversity jurisdiction? Alexander claims parties are diverse Not stated Both parties are PA citizens; no diversity
Does the complaint state a federal cause of action? Complaint alleges breach of contract/eviction Not stated No plausible federal claim alleged
Can the complaint proceed as pled? Alexander seeks court protection and damages Not stated Dismissed for lack of subject matter jurisdiction

Key Cases Cited

  • Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standard for plausibility of claims at pleadings stage)
  • Lincoln Ben. Life Co. v. AEI Life, LLC, 800 F.3d 99 (3d Cir. 2015) (party alleging subject-matter jurisdiction bears the burden of proving it)
  • Zambelli Fireworks Mfg. Co. v. Wood, 592 F.3d 412 (3d Cir. 2010) (section 1332(a) requires complete diversity for jurisdiction)
  • Lincoln Prop. Co. v. Roche, 546 U.S. 81 (2005) (diversity jurisdiction demands no plaintiff is a citizen of same state as any defendant)
  • Krasnov v. Dinan, 465 F.2d 1298 (3d Cir. 1972) (residency vs. domicile in evaluating citizenship for diversity jurisdiction)
Read the full case

Case Details

Case Name: ALEXANDER v. GREYSTAR
Court Name: District Court, E.D. Pennsylvania
Date Published: Jul 2, 2025
Citation: 2:25-cv-03300
Docket Number: 2:25-cv-03300
Court Abbreviation: E.D. Pa.